Buffalo Naval Park Committee Inc. v. Water Quality Insurance Syndicate
- Rochon
- 1:25-cv-06344
- U.S. District Court · Southern District of New York
- 2
In Buffalo Naval Park v. Water Quality, Judge Rochon ordered citizenship allegations amended to establish federal jurisdiction.
Buffalo Naval Park Committee Inc. must amend its complaint by August 12, 2025, to identify the citizenship of each person or entity comprising Water Quality Insurance Syndicate. If it does not do so adequately, the court will dismiss the action for lack of subject matter jurisdiction without further notice.
What happened
Buffalo Naval Park Committee Inc. sued Water Quality Insurance Syndicate in federal court, relying on diversity jurisdiction, which allows certain lawsuits involving citizens of different states or countries.
The complaint identified the plaintiff as a New York not-for-profit corporation and the defendant as an unincorporated association of marine insurers. The court explained that an unincorporated association has the citizenship of each of its members, but the complaint did not identify those members’ citizenship.
Judge Jennifer L. Rochon ordered the plaintiff to amend its complaint by August 12, 2025, to allege the citizenship of every person or entity comprising Water Quality Insurance Syndicate. The court said it will dismiss the case for lack of subject matter jurisdiction if the plaintiff does not adequately amend the complaint.
The detailed version
- Buffalo Naval Park Committee Inc. v. Water Quality Insurance Syndicate · No. 1:25-cv-06344
- Rochon
- Aug. 5, 2025
Background
Buffalo Naval Park Committee Inc. brought the action against Water Quality Insurance Syndicate, invoking diversity jurisdiction under 28 U.S.C. § 1332. Diversity jurisdiction is federal jurisdiction over certain disputes involving citizens of different states or citizens of the United States and foreign states.
The complaint alleged that Buffalo Naval Park Committee Inc. is a New York not-for-profit corporation with offices in Buffalo, New York. It alleged that Water Quality Insurance Syndicate is an unincorporated association of marine insurers with an office and principal place of business in New York. The court explained that, for diversity purposes, an unincorporated association has the citizenship of each of its members. Because the complaint did not allege the citizenship of those members, it did not adequately establish diversity jurisdiction.
Order
Judge Jennifer L. Rochon ordered the plaintiff to amend the complaint by August 12, 2025, to allege the citizenship of each person or entity comprising Water Quality Insurance Syndicate. The court stated that, if the plaintiff does not adequately allege the parties’ citizenship by that date, it will dismiss the action for lack of subject matter jurisdiction without further notice.
The order addressed the court’s jurisdiction and did not decide the underlying dispute between the parties.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.